Governance & SMF Structure Review

Most firms only discover a gap in their SMF governance structure when a supervisor asks a pointed question they can’t answer cleanly, or when something goes wrong and the accountability turns out to be unclear. SMF Capital offers an independent review of your existing SMF population, Statements of Responsibilities and Responsibilities Map — surfacing gaps, overlaps and drift before they become a live problem, not after.

What the Review Actually Covers

Coverage against your firm’s tier requirements

We check your current SMF holders against what your firm’s actual tier — Limited Scope, Core or Enhanced — requires, and flag anywhere the two don’t line up, including firms that have grown into Enhanced tier requirements without fully updating their governance structure to match.

Responsibilities Map accuracy

For Enhanced tier firms, we review whether your Responsibilities Map genuinely reflects your current management structure, or whether it’s drifted out of date as the business has evolved — a common and easily overlooked source of exposure.

Gaps and overlaps between individual Statements of Responsibilities

We check whether your SMF holders’ individual Statements of Responsibilities, read together, actually cover the whole business with no material gaps and no confusing overlaps — the specific failure pattern regulators look for when something goes wrong and no single person can be shown to have owned the area involved.

Genuine independence of control functions

We assess whether your SMF4, SMF5, SMF16 and SMF17 holders have real structural independence from the business lines they oversee — reporting lines, resourcing, and genuine authority to challenge — rather than independence that exists only on an organisation chart.

Proportionality of fractional and interim arrangements

Where you’re using fractional or interim cover for any SMF designation, we assess honestly whether the arrangement is still proportionate to your current scale, or whether growth has quietly outpaced it.

What You Get

A clear, prioritised report setting out what we found, ranked by genuine regulatory exposure rather than a flat checklist — distinguishing between a minor documentation tidy-up and a structural gap that needs addressing urgently. Where a gap points to a recruitment need, we’ll tell you plainly, and can move directly into a search; where it’s a documentation or process fix your own team can handle, we’ll say that too rather than manufacturing a recruitment need that isn’t there.

Who This Is For

Firms approaching a tier transition who want to know what’s actually required before they’re caught by it. Boards inheriting a governance structure they didn’t build and want independently checked. Firms that have grown quickly and suspect, without being certain, that their SMF documentation hasn’t kept pace. And firms simply due a periodic health check, since a Responsibilities Map and Statement of Responsibilities set are living documents that drift without active maintenance, not one-off deliverables.

Why an Independent Review, Not Just Internal Compliance Sign-Off

Internal compliance teams are close to the day-to-day reality of the business, which is valuable, but that closeness can also make it harder to spot structural gaps that have become normalised over time — an overlap everyone’s quietly worked around, or a reporting line that’s technically compliant but practically compromised. An outside review, run by someone who assesses this exact question across many firms rather than one, tends to surface exactly the kind of drift that’s hardest to see from inside.